Privacy Policy

Effective Date: January 29, 2026

Welcome to Shuffle, a service of DNFT, Inc. ("DNFT", "Company", "we", "us", or "our"). This Privacy Policy explains how we collect, use, share, and protect your information when you use our websites, applications, messaging services, AI-powered features, and related software (collectively, the "Service").

By using the Service, you consent to this Privacy Policy and our Terms of Service. If you do not agree, please discontinue use of the Service.

1. Information We Collect

1.1 Information You Provide

Messages and Content

When you interact with our AI-powered features, we receive and process:

  • Text messages you send to the Service
  • Images, videos, and other media you share
  • Voice recordings (if you use voice call features)
  • Metadata associated with your messages (timestamps, conversation identifiers)

Contact Information

When you use or register for the Service, we collect:

  • Phone number (required for SMS/iMessage service)
  • Name (if provided)
  • Email address (if provided)

Billing Information

For paid subscriptions, we collect payment and billing details through our secure third-party payment processor, Stripe, Inc. We do not store full credit card numbers on our servers; we only retain a payment token and the last four digits of your card for reference.

Communications with Us

When you contact our support team, we collect the content of your communications.

1.2 Information Automatically Collected

Message Metadata

  • Message timestamps and delivery status
  • Conversation identifiers
  • Message routing information
  • Conversation size and participant count (for group chats)

Usage Data

  • Features you use and how you interact with them
  • Frequency and volume of usage
  • Device type and operating system
  • Browser type (for web access)
  • IP address

Carrier and Network Data

  • Mobile carrier information
  • SMS/MMS delivery data provided by carriers

Safety and Abuse Detection Data

We automatically collect and analyze data to detect potential child exploitation, abuse, and violations of our Terms, including:

  • Behavioral patterns
  • Content characteristics
  • Risk indicators
  • Device and account signals

1.3 Information from Third Parties

We may receive information from:

  • Communications carriers (delivery status, routing data)
  • Payment processors (transaction status)
  • Analytics providers (aggregated usage data)

2. How We Use Information

We use the information we collect to:

Provide and Operate the Service

  • Process your messages and generate AI responses
  • Maintain conversation context and memory
  • Generate images and other content you request
  • Deliver features like reminders, games, and search

Improve the Service

  • Analyze usage patterns to improve features
  • Develop new features and capabilities
  • Train and improve AI models (including using your content to train our models)
  • Fix bugs and technical issues

AI Model Training Disclosure

Your content (messages, images, inputs) may be used to train, fine-tune, and improve AI models operated by DNFT. To opt out of DNFT's internal model training, email privacy@dnftinc.com with subject "Model Training Opt-Out."

Important: Opting out applies to future data only and does not affect content already used for training. Your opt-out does not change how third-party AI providers (OpenAI, Anthropic, Google, etc.) handle data under their own policies. For a list of our current service providers, contact privacy@dnftinc.com.

Communicate with You

  • Respond to your support requests
  • Send service-related notifications
  • Send billing and account information
  • Provide updates about changes to the Service

Safety and Security

  • Detect and prevent fraud, abuse, and security threats
  • Enforce our Terms of Service
  • Protect children (detect and report exploitation)
  • Verify user age and identity

Legal Compliance

  • Comply with applicable laws and regulations
  • Respond to legal process and government requests
  • Protect our legal rights

3. How We Share Information

We do not sell personal information for money. We may share certain identifiers (such as device IDs and usage data) with advertising partners for measurement or retargeting purposes, which may be considered a "sale" or "sharing" under California law—see Section 7.2 for your opt-out rights.

We share information in the following circumstances:

3.1 Service Providers

We share information with trusted third-party service providers who help us operate the Service, including:

AI Model Providers

  • OpenAI
  • Anthropic
  • Google
  • Perplexity
  • Other AI/ML service providers

These providers process your inputs to generate AI responses. They operate under contractual obligations to protect your data.

Infrastructure Providers

  • Cloud hosting services (AWS, Google Cloud, etc.)
  • Content delivery networks
  • SMS/MMS gateway providers

Payment Processing

  • Stripe, Inc. (payment processing)

Analytics

  • Service analytics tools (aggregated data only)

Advertising and Retargeting Partners

We may share certain information with advertising and analytics partners for purposes including:

  • Measuring the effectiveness of our advertising campaigns
  • Retargeting (showing you ads on other platforms based on your interactions with us)
  • Audience insights and analytics

These partners may include platforms such as Meta (Facebook/Instagram), Google Ads, and similar services. Information shared may include device identifiers, IP addresses, and usage data. This sharing may constitute a "sale" or "sharing" of personal information under California law—see Section 7.2 for your opt-out rights.

What We Do NOT Share with Advertising Partners:

  • Message content (your conversations with Shuffle)
  • Images you send or receive
  • Phone numbers
  • Billing or payment information

3.2 Child Safety Reporting

We report suspected child sexual abuse material (CSAM) and child exploitation to:

  • National Center for Missing & Exploited Children (NCMEC)
  • Appropriate law enforcement authorities

3.3 Legal Requirements

We may disclose information when required by law, including:

  • Valid subpoenas, court orders, or legal process
  • Government or regulatory requests
  • To protect our legal rights or defend against legal claims
  • In emergencies involving potential threats to safety

3.4 Business Transfers

If DNFT is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

3.5 With Your Consent

We may share information for other purposes with your explicit consent.

4. AI Processing and Third-Party AI Providers

4.1 How AI Processing Works

The Service uses artificial intelligence to process your messages and generate responses. Your inputs (messages, images, etc.) are sent to AI model providers for processing. These providers include OpenAI, Anthropic, Google, Perplexity, and others.

4.2 What AI Providers Receive

AI providers may receive:

  • The content of your messages
  • Conversation context necessary to generate relevant responses
  • Image and media content you submit for processing

4.3 AI Provider Data Practices

Our AI providers operate under contractual agreements that include data protection requirements. However, you should be aware that:

  • AI providers may have their own data retention policies
  • Some providers may use data to improve their AI models (subject to their terms)
  • We select providers with strong privacy and security practices

5. Data Retention

5.1 Retention Periods

Data TypeRetention Period
Message contentDuration of your account, plus up to 90 days after deletion
Conversation context/memoryDuration of your account
Account informationDuration of your account, plus up to 2 years for legal compliance
Billing records7 years (legal/tax requirements)
Safety-related dataAs long as necessary for safety, legal compliance, and investigations
Analytics dataAggregated/anonymized data may be retained indefinitely

5.2 Deletion Requests

You may request deletion of your data by contacting privacy@dnftinc.com. We will delete your data within 30 days, except where we are required or permitted to retain it for:

  • Legal compliance
  • Fraud prevention
  • Child safety investigations
  • Resolving disputes

6. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, use, or disclosure. These measures include:

  • Encryption of data in transit
  • Access controls and authentication requirements
  • Employee training on data protection
  • Incident response procedures
  • Engagement of reputable infrastructure and service providers

Important Notice: No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the security of your device and account credentials.

7. Your Privacy Rights

7.1 All Users

All users have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Request deletion of your information (subject to legal exceptions)
  • Opt out of promotional communications

7.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know

You have the right to request information about:

  • The categories of personal information we collect
  • The purposes for which we use your information
  • The categories of third parties with whom we share information
  • The specific pieces of personal information we have collected about you

Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

Right to Opt-Out of Sale/Sharing

We may share certain personal information (such as device identifiers and usage data) with advertising and analytics partners for retargeting and measurement purposes. Under California law, this may constitute a "sale" or "sharing" of personal information.

You have the right to opt out of the sale or sharing of your personal information.

To opt out:

We will process your request within 15 business days. Note: Opting out of sale/sharing does not affect our use of your data to provide the Service or for non-advertising purposes.

Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

"Shine the Light" (California Civil Code § 1798.83)

California residents may request information about disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

How to Exercise Your Rights

Submit requests to: privacy@dnftinc.com

We will verify your identity before processing requests. We will respond within 45 days (or 90 days for complex requests).

7.3 Other U.S. State Rights

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights. Contact us at privacy@dnftinc.com to exercise your rights.

7.4 International Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you may have additional rights under the General Data Protection Regulation (GDPR):

  • Right of access
  • Right to rectification
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object
  • Rights related to automated decision-making

Legal Basis for Processing

We process your data based on:

  • Performance of a contract (providing the Service)
  • Legitimate interests (security, fraud prevention, service improvement)
  • Legal obligations
  • Your consent (where required)

International Transfers

Your data is processed in the United States. By using the Service, you consent to the transfer of your data to the United States, which may have different data protection laws than your country.

Data Protection Authority

You have the right to lodge a complaint with your local data protection authority.

8. SMS/Text Message Consent

8.1 Program Description

Shuffle is an AI-powered messaging service that provides conversational AI assistance, image generation, information retrieval, reminders, games, and other features via SMS and iMessage. When you text our service number, you interact with an AI assistant that responds to your messages.

8.2 Consent and Message Types

By providing your phone number and using the Service, you expressly consent to receive SMS and MMS messages from Shuffle at the phone number you provide. Messages fall into two categories:

Transactional Messages (required for Service operation):

  • AI-generated responses to your messages
  • Service-related notifications (account, security, billing)
  • Scheduled nudges and reminders (if enabled)
  • Verification codes

Promotional Messages (optional):

  • Special offers and discounts
  • New feature announcements
  • Marketing communications

Promotional messages require your express written consent. You may receive promotional messages if you opt in through our website or by texting a promotional keyword.

Consent to receive promotional messages is not required to use the Service or make a purchase.

8.3 Message Frequency

Message frequency varies based on your usage:

  • AI responses: You will receive a response each time you message us (typically within seconds to minutes).
  • Transactional: As needed for account activity, security, or features you enable.
  • Promotional: If opted in, up to 4 promotional messages per month.

8.4 Costs

Msg and data rates may apply. You are responsible for any charges from your mobile carrier. Contact your carrier for details about your messaging plan.

8.5 Help and Support

For help, visit our website or contact us at:

8.6 Opt-Out / Stop

To stop receiving all messages and disable the Service for your phone number, text any of the following:

  • STOP
  • UNSUBSCRIBE
  • OPT-OUT
  • OPT OUT

Important: Texting STOP will disable the entire Service for your phone number. You will no longer receive AI responses, transactional messages, or promotional messages.

To reactivate, send any message to our service number.

To opt out of promotional messages only (while keeping the Service active), email support@dnftinc.com with subject "Opt Out Promotions."

8.7 Consent Revocation

You may revoke your consent to receive messages at any time by texting STOP or contacting us. Revocation will take effect within 24 hours. Note that revoking consent will disable the Service, as messaging is required for the Service to function.

9. Children's Privacy

The Service is intended for users 13 years of age and older. Children under 13 are strictly prohibited from using the Service.

9.1 Age Verification

We do not independently verify the age of our users. We rely on users to self-represent their age accurately. By using the Service, you represent that you are at least 13 years old.

9.2 Users Ages 13-17

Users between 13 and 17 may use the Service only with parental or guardian consent and supervision. We do not verify parental consent; parents and guardians are solely responsible for:

  • Providing consent for their minor's use of the Service
  • Monitoring their minor's use and interactions
  • Ensuring appropriate use of the Service

9.3 COPPA Compliance (Under 13)

We do not knowingly collect personal information from children under 13. If we obtain actual knowledge that we have collected information from a child under 13, we will immediately:

  • Terminate the account
  • Delete all associated personal information
  • Report to NCMEC if any child exploitation is suspected

9.4 Reporting Underage Users

If you believe a child under 13 is using the Service, please report it immediately to:

  • Email: support@dnftinc.com (subject: "Underage User Report")
  • Include any relevant information to help us identify the account

10. Do-Not-Track Signals

Some browsers transmit "Do Not Track" (DNT) signals. There is no industry standard for how to respond to DNT signals. Currently, the Service does not respond to DNT signals. If a standard is adopted, we will update this policy.

11. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by:

  • Posting the updated policy on our website with a new effective date
  • Sending notice to your phone number or email (if available)

Your continued use of the Service after changes take effect constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us:

General Privacy Questions:

Email: privacy@dnftinc.com

Data Deletion Requests:

Email: privacy@dnftinc.com

Subject Line: "Data Deletion Request"

Mailing Address:

DNFT, Inc.
Attn: Privacy
251 Little Falls Drive
Wilmington, DE 19808

Support:

Email: support@dnftinc.com

Website: https://addshuffle.com

Last Updated: January 29, 2026

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